‘Tis the season to obtain certainty

October 2013


A pre-filing agreement (PFA) allows a taxpayer to obtain certainty on an issue before the filing of its return. Specifically, it results in a closing agreement that precludes the IRS from challenging the issue in any subsequent examination of the taxpayer’s return.

Since the optimal time for requesting a PFA for a calendar year taxpayer is at the end of a filing year and the first two or three months following the close of the tax year, this is a good time to consider the use of a PFA for appropriate issues for calendar year 2013 tax returns.

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Pam Olson
US Deputy Tax Leader & Washington National Tax Services Leader
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